Although most federal contractors have been focused on compliance with COVID-19 vaccination mandates (as discussed here and here), it’s important to take a moment to look at another compliance topic related to equal employment opportunity obligations. On 2 December 2021, the Office of Federal Contract Compliance Programs (OFCCP) announced it is moving forward with an Affirmative Action Program (AAP) Verification Interface (Contractor Portal) to facilitate receipt of certifications verifying compliance. The Contractor Portal will provide a mechanism for covered federal contractors and subcontractors to certify annually whether they have complied with their obligations to develop and maintain AAPs for each establishment or functional unit,1 as applicable. Further, the Contractor Portal will establish a secure method for contractors scheduled for compliance evaluations to submit their AAPs to OFCCP.
As background, affirmative action requirements help ensure that applicants and employees of federal contractors have equal employment opportunity without regard to their race, color, religion, sex, sexual orientation, gender identity, national origin, disability, or status as a protected veteran. Covered federal contractors that satisfy certain thresholds are required to develop and maintain AAPs on an annual basis. More specifically, federal contractors that hold a contract of US$50,000 or more and employ 50 or more employees are required to develop and maintain AAPs pursuant to...
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